https://www.taxtmi.com/caselaws?id=472664 Transfer-pricing benchmarking under Section 92 is confined to operating costs attributable to international transactions with associated enterprises; applying the arm's length margin to costs of non-associated-enterprise transactions is impermissible. Component manufacturers should not be compared with manufacturers of complete telecom or process-control equipment, while comparables affected by amalgamation or related-party transactions require verification. Foreign-exchange gains or losses directly arising from import and export trading form operating items. Depreciation-method differences may distort operating-profit comparability and require reassessment of the profit level indicator; the treatment of excise duty in operating cost requires factual examination. Under TNMM, arm's length pricing should use a reasonable number of comparables rather than a single most favourable comparable. en-us Mon, 01 Nov 2021 00:00:00 +0530 Wed, 21 Oct 2026 15:41:22 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=472664 Transfer-pricing benchmarking under Section 92 is confined to operating costs attributable to international transactions with associated enterprises; applying the arm's length margin to costs of non-associated-enterprise transactions is impermissible. Component manufacturers should not be compared with manufacturers of complete telecom or process-control equipment, while comparables affected by amalgamation or related-party transactions require verification. Foreign-exchange gains or losses directly arising from import and export trading form operating items. Depreciation-method differences may distort operating-profit comparability and require reassessment of the profit level indicator; the treatment of excise duty in operating cost requires factual examination. Under TNMM, arm's length pricing should use a reasonable number of comparables rather than a single most favourable comparable. Case-Laws Income Tax Mon, 01 Nov 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=472664